On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more
Managing Decommissioning Risks in Asian M&A Transactions -
By the end of 2026, approximately 134 producing Concessions and Production Sharing Contracts (each, a “PSC”) will have expired in South Asia. It is expected that 900...more
9/15/2017
/ Acquisitions ,
Asia ,
Cross-Border ,
Electricity ,
Force Majeure Clause ,
Greenhouse Gas Emissions ,
Hackers ,
IRS ,
Liquid Natural Gas ,
Mergers ,
Oil & Gas ,
Renewable Energy ,
Supply Chain ,
Take-or-Pay Contracts ,
Tax Reform
On July 26, 2017, the Tax Court issued its opinion in Eaton Corp. v. Commissioner, holding that the IRS’s cancellation of two advance pricing agreements (“APAs”) reached with Eaton Corporation (“Eaton”) was “arbitrary and...more
In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more